Global Migrations Limited- Privacy Notice
This Privacy Notice was last updated: 01 December 2020.
This Privacy Notice (“Notice”) describes how Global Migrations Limited (we, us, our or Global Migrations) may use, process, store and disclose Personal Information that we may collect about individuals, including if you register or provide your details through this website and from other sources, such as when you apply for a job through job sites such as Indeed, Totaljobs, Jobserve, and Jobsite. The types of data we collect are described in the section below ‘Your Personal Information and how we collect it’.
We act as a controller and we are responsible for the Personal Information we process. This Notice informs you how we protect your Personal Information and informs you about your privacy rights.
It is important that you read this Notice together with any other Privacy Notice we may provide such as the Notice contained in our Candidate Registration form and on specific occasions when we are collecting or processing your Personal Information so that you are fully aware of how and why we are using your Personal Information. This Notice supplements other Privacy Notices you may receive from us and is not intended to override them.
This website is not intended for children and we do not knowingly collect data relating to children.
Contact Details
If you have any questions about how we use your Personal Information, contact us at: info@globalmigrationltd.com
Your Personal Information and how we collect it
Using this Website
When you use this website, we may ask for certain Personal Information including your name and contact information (email, home address and phone number). Depending on the nature of your enquiry or activities on our website, we may also ask for your job search criteria and preferences, employment experience, salary, and other background information together with any login ID and password created by you. You can request us to send you job alerts through the website by completing your job search criteria and preferences. You can stop receiving these job alerts at any time by clicking on the unsubscribe link contained in the job alert email.
Registering as a Candidate for work finding services
We will collect your Personal Information directly from you and from other sources including when you apply for a job via a Job Board, directly through our website, from Social Media sites such as LinkedIn, Facebook and Twitter or when you provide us with your details during a job fair, promotional, networking or training event. When you ask us to provide you with work finding services we will ask you to register as a Candidate. During our Candidate Registration process we will collect your Personal Information directly from you, your CV, from employment and educational referees and via online tests you may perform at our request. We may disclose your Personal Information to our Clients in Africa, UK, Europe and outside the EEA for relevant job vacancies. Our Clients may request additional Personal Information about you in relation to their job vacancies and requirements. Your Personal Information will be securely stored in our online candidate database.
The categories of Personal Information we may collect include:
To provide you with work finding services our recruitment consultants will send you job alert emails matching your job search criteria and preferences. From time to time you may also receive job alerts which our consultants consider you may find interesting.
You can stop receiving these job alerts at any time by clicking on the unsubscribe link contained in the job alert email.
Applicants for Employed Roles
If you are applying for a role as our employee, we will collect Personal Information from you via your CV, referees, professional and educational organisations and other sources. We will process your Personal Information for the purposes of administering the application, managing the internal hiring process and assessing your suitability. We will store your Personal Information securely in our confidential online HR database. Your Personal Information cannot be viewed or accessed by anyone except for members of HR and Talent Acquisition in the UK, Europe and the US and other staff if they are connected to the hiring process, such as interviewing, assessing your suitability for the role you have applied for and communicating with you. We do not share our HR database with any group companies and we will take steps to ensure that your Personal Information is adequately protected, secure and kept confidential. If we engage a third party to provide pre-employment screening services or testing, we will ensure that access is limited to the Personal Information that is compatible with those services and the service provider is contractually obliged to comply with applicable data privacy laws, confidentiality and provide adequate safeguards to keep your Personal Information secure until it is deleted or anonymised.
By applying for employment with us, you consent to us processing your Personal Information for these purposes. You have the right to withdraw your consent at any time. If you withdraw your consent, we will not be able to continue with your application.
If your employment application is unsuccessful, we will retain your Personal Information on our HR database for a period of 6 months for the purposes of evidencing that we have conducted the recruitment process in a fair and transparent way and have not discriminated against applicants on prohibited grounds. At the end of the retention period, your Personal Information will be automatically deleted. Occasionally we may ask if you would like us to retain your CV data if we consider that you may be suitable for future roles. We will only do this with your consent.
Special Categories of Personal Information
Details about your health, unspent criminal or motoring convictions, court proceedings, or any pending proceedings relating to an offence committed or alleged to have been committed by you is only processed if it is relevant (for example to enable us to assess whether these present grounds for not taking your candidate registration or job application further) and in accordance with the restrictions imposed by law. We may be obliged to disclose unspent convictions and criminal proceedings to our clients so that they can determine if these are relevant to your suitability for a role within their organisation. This information will be retained for no longer than necessary before being deleted.
Our Clients and Suppliers
If you are a Client or supplier or a potential client or supplier, of goods and services we will collect and process information about individuals in your organisation. We may enter the individual’s name and business email address in to our database as a designated corporate point of contact for that organisation, together with the individual’s other business contact data. Usually the only Personal Information we process about a corporate contact is the individual’s name for the purposes of contacting the organisation in relation to our services and authorising time sheets or the supplier as a recipient of the supplier’s goods and services. If the individual corporate point of contact is also a registered candidate we may be processing additional Personal Information for work finding and other purposes as described in this Notice. The source of a corporate point of contact may be the individual themselves, or their name and business details may be provided to us by a member of their HR or Procurement department or another hiring manager or existing business contact or a candidate we have placed at the organisation. We may also obtain these details from websites, social media and other sources. We may send business to business email marketing to corporate points of contact. An individual corporate point of contact can ask us at any time to stop sending business marketing emails to their business email address by contacting: info@globalmigrationltd.com
How we use your Personal Information
We use, process, store and disclose your Personal Information and other data we collect including during our Candidate Registration process, to provide you with work finding services including sending you job alerts through this website and by email, temporary assignments, project related work and permanent and fixed term contract placements in finance, accounting, technology, administrative, legal, marketing and other related roles, employment opportunities and career-related information. We will process your Personal Information in accordance with our candidate contract (provided during our candidate registration process) applicable to the type of work you are seeking and we will disclose your Personal Information to our Clients in relation to their job vacancies. We will also process your Personal Information for other legitimate business purposes such as producing statistics, analysing how successful our marketing campaigns are, the number of visitors to our website and complying with other contractual, legal and regulatory obligations and duties. If you provide us with information about 3rd parties, we will assume that the 3rd party in question has given you permission to do so and to Global Migrations collecting, processing and transferring their Personal Information to the same extent as yours.
Currently we do not use automated decision making technologies to make final or conclusive decisions about you and a member of our staff will always be involved in the provision of working finding services.
Change of Purpose
We will only use your Personal Information for the purposes for which we collected it (e.g. the provision of work finding services if you are a candidate or to consider you for employment if you are a job applicant), unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
We may process your Personal Information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Transferring your Personal Information outside of the UK / Europe
Global Migrations Limitedis company that serves companies globally. We may share some of your Personal Information with our group companies within or outside the UK and European Economic Area (EEA), who may use and process your Personal Information for similar purposes as described in this Notice. The data protection laws outside the UK and Europe may not provide an equivalent level of protection to those in the UK and in these circumstances we will take steps to ensure that your Personal Information is adequately protected, secure, kept confidential and that we have a lawful basis for the transfer. This means we may require the 3rd party recipient to sign the EU Model Contract clauses approved by the European Commission as providing personal data with the same protection that your Personal Information has when it is processed within UK/EEA.
When we transfer your Personal Information to 3rd parties based in the US, we will check if they are a member the EU/US Privacy Shield (as Membership requires the business to provide similar protection to personal data shared between the UK, Europe and the US). If they are not Privacy Shield certified, we will ensure these recipients will only process your Personal Information on our instructions and they will be subject to a duty of confidentiality and required to sign the EU Model Contract.
You can contact us if you require further information on the mechanism we use when transferring your Personal Information out of the UK/EEA.
Disclosing your Personal Information to 3rd Parties
To the extent necessary or appropriate and without notifying you, Global Migrations may disclose your Personal Information to external 3rd parties (who are not members of the Global Migrations group of companies) in the following circumstances:
Where applicable, we will impose appropriate contractual, security, confidentiality and other obligations on to 3rd party service providers and processors we have appointed, based on the nature of the services they provide to us. We will only permit them to process your Personal Information in accordance with the law and our instructions. We do not allow them to use your Personal information for their own purposes and when our relationship ends we will ensure your Personal Information is securely returned or destroyed or anonymised so that you can no longer be identified.
Some of these 3rd parties are also controllers responsible for processing your Personal Information for their purposes, for example, HM Revenue & Customs is a controller for tax purposes. We may not be able to impose obligations or restrictions on these controllers in connection with how they process your Personal Information.
Keeping your Personal Information Secure
We have put in place appropriate security measures to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to do so.
We have put in place procedures to deal with any suspected Personal Information breaches and we will notify you and the applicable supervisory authority of a breach where we are legally required to do so.
How long we Retain your Personal Information
Global Migrations will retain your Personal Information for as long as necessary to fulfil the purposes that we collected it for. This means we will keep your Personal Information throughout the period of your relationship with us and whilst we are providing you with work finding services.
If you no longer wish to receive our services you can request us to delete your Personal Information from our Candidate database. When we have deleted your data, we may retain your name and email address on our suppression list and subject to the services we have provided, continue to retain some of your Personal Information for our legitimate business purposes described below.
We are required by law to keep basic information about our Candidates, Clients and customers (including contracts, evidence of identity, and right to work in the UK, financial and transaction data) for up to 7 years from when our relationship ends, for legal, compliance and tax purposes.
Where there is no retention period stated in law, we determine the appropriate retention period for Personal Information by considering the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of the data, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your Personal Information (so that it can no longer be associated with you and we cannot identify you). We do this for research or statistical purposes in which case we may use this anonymised data indefinitely without further notice to you.
Details of the retention periods for different aspects of your Personal Information are set out in our Record Retention and Destruction Policy which you can request from us by contacting us at: info@globalmigrationltd.com.
Your Legal Rights
You have the right to:
Make a Data Subject Access Request to access your Personal Information at any time. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
Request erasure / deletion / removal of your Personal Information. This enables you to ask us to delete or remove your Personal Information where we do not have a valid reason to continue to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Please Note: we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a 3rd party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to process it.
Data Portability / Request the transfer of your Personal Information to you or directly to another controller. This right only applies to automated information which you initially provided consent for us to use or where we used the Personal Information to perform a contract with you. We will (unless there is an exemption) assist you by securely transferring your Personal Information directly to another controller where technically feasible or by providing you with a copy in a structured commonly used machine readable format. The data we can provide is:
Report Title |
Candidate Information |
Objects |
Personal Details |
Full name, address, phone number, e-mail (business/personal), nationality, place of birth, birthdate, gender. Online presence URLs. Emergency contact name and phone. |
Contact People Address Phone Online Presence |
Eligibility Details |
National ID, tax information. Work visa / passport details. Full name, business phone number and company name of job references. |
Contact Candidate Country Eligibility |
Education and Skills |
Skills and skill test results. Education certifications and qualifications with dates. Industries worked in. |
Contact Candidate Skills |
Work History |
Work history (employer, job title/function, employment dates, remuneration). |
Contact Candidate Employment History |
Job Placement/role |
Job placement /employment (company, job title/function, start date, end date, compensation/pay rates, worksite addresses). |
Contact Job Order Company Address |
Withdraw consent at any time where we are relying on your consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
We want to ensure we keep your Personal Information accurate and up to date. In addition to your legal rights, you may ask us to make changes or request a copy of your Personal Information informally, by contacting your local Global Migrations branch.
Additional Information, Response Times and Fees
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights or when you make an informal request). This is a security measure to ensure that Personal Information is not disclosed to any person other than the individual who has the right to receive it. We may also contact you to ask you for further information in relation to your request to help us locate your data and to speed up our response.
We try to respond to all legitimate requests within one month. It may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Purpose/Activity |
Type of Personal Information |
Lawful basis for processing Personal Information |
To register you as a candidate for work finding services or when you make an employment application to us |
(a) Identity (b) Contact details (c) Evidence of your right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions |
Fulfil a contract (the BER Candidate Agreement); Legal or regulatory duty (complying with the recruitment industry and immigration regulations) To administer your registration or employment application |
To provide you with work finding services including: sending you details of available job opportunities and job alert emails in accordance with your job search preferences and criteria, providing career advice, providing your CV to clients in relation to their job vacancies / roles), paying your wages (if you are a temporary worker) paying your fees if you work through an umbrella or a Limited Company, and charging clients for placements we make. |
(a) Identity (b) Contact details (c) Financial data (d) Transaction data (e) Marketing and Communications |
Fulfil a contract (BER Candidate Agreement and Client Contracts); Legitimate interests Legal or regulatory duty Your consent |
Transferring your Personal Information to our group companies (including Bethesda Recruitment Ltd in the UK) and to our other group companies in the US |
(a) Identity (b) Contact details (c) Evidence of your right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions |
Legitimate interests including work finding services Your consent |
Disclosing your Personal Information to government and law enforcement agencies and our appointed 3rd party vendors providing goods and services. including vendors located in the US, and providing Cloud based services |
a) Identity (b) Contact details (c) Evidence of your right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions |
Legitimate interests Legal or regulatory duty |
To manage our relationship with you including: (a) Notifying you about changes to our Candidate Agreement or Privacy Notices (b) Asking you to leave a review or feedback or complete a survey (c) administration and IT services connected with representing you for roles, placing you in temporary assignments to work for our clients, processing timesheets, payroll and other payments, tax deductions, issuing payslips, etc |
(a) Identity (b) Contact (c) Profile/Survey (d) Marketing and Communications |
Fulfil a contract Legal or regulatory duty Legitimate interests (keeping our records updated and to study how candidates and potential candidates and visitors to our website use our services and website, to develop and improve them and to grow our business |
Keeping your Personal Information secure to prevent it from being lost, used, accessed, disclosed or altered in an authorised way |
(a) Identity (b) Contact details (c) Evidence of your right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions |
Legal or regulatory duty Legitimate interests Fulfil a contract |
To investigate issues, disputes and complaints between us, and between us, you and our clients and to respond and seek to resolve them |
(a) Identity (b) Contact (c) Profile (d) Usage data (e) Marketing and Communications |
Legitimate interests Fulfil a contacts |
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical data |
Legitimate interests Legal or regulatory duty |
For Marketing and communications, make suggestions and recommendations to you about other relevant services that may be of interest to you (e.g. the Global Migrations Newsletter, Salary Guides, Online training |
(a) Identity (b) Contact (c) Technical data (d) Usage data (e) Profile data |
Legitimate interests (send you salary guides and other relevant information) Where we have a business relationship with you, sending you marketing based on the ‘soft opt in’ Your consent. |
To deliver relevant website content and measure or understand the effectiveness of our advertising |
(a) Identity (b) Contact (c) Profile data (d) Usage data (e) Marketing and Communications (f) Technical data |
Legitimate interests (to study how customers use our products/services/website, to develop them, to grow our business and to inform our marketing strategy) Your consent |
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
(a) Technical data (b) Usage data (c) Profile data |
Legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) Your consent |
Retaining your Personal Information for as long as necessary for the purposes of providing you with work finding services or to manage the internal hiring process for employed roles |
(a) Identity (b) Contact details (c) Evidence of your right to work in the UK (d) CV (e) referees (f) unspent criminal / motoring convictions |
Legitimate interests Legal or regulatory duty |
To help us respond to queries, and requests from regulators, government and law enforcement agencies such as HMRC and the Police |
(a) Contact |
Legitimate interests Legal or regulatory duty |
The Legal Basis for processing your Personal Information
We have set out a short description of main ways we will collect, store, process, share and disclose your Personal Information and the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
We will only use your Personal information when the law allows us to. Most commonly, we will use your Personal information in the following circumstances:
A legitimate interest is when we have a business or commercial reason to use your information in conducting and managing our business. We will consider and balance any potential impact on you and your legal rights when we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required for compliance with a legal or regulatory obligation or permitted to by law).
Marketing Messages
We will ask you for consent to send your direct marketing communications via email. However, where we are providing you with work finding services, you will receive email marketing communications from us even if you have not given us consent as we rely on the ‘soft opt in’ form of consent.
You may receive marketing communications from us if you provided us with your details when you entered a competition or registered with us at a job fair, promotional or networking event or attended a training course and you have given us consent to send you marketing. If you give us consent we may also use your identity, contact details, technical data, usage data and profile data to form a view and decide which services may of interest or relevant for you.
We have established an email preference centre where you can view and make decisions about your email marketing preferences and opt out of receiving email marketing from us at any time.
You have the right to withdraw your consent to marketing at any time by:
Opting out of receiving marketing messages does not apply to:
We will never sell or disclose your Personal Information to any 3rd parties to use for marketing.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, and to manage your cookie settings please see our Cookies Policy.
Links to other websites
Our website may include links to 3rd party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these 3rd party websites and are not responsible for their privacy statements.
Customer Feedback and Complaints
If you would like to share your experience of working with us, whether it’s to tell us it our staff were great and found you work or if something isn’t quite right, we want to hear about it.
You can provide feedback to your contact in your local Global Migrations branch, or their manager. If you are not entirely satisfied with a response you have received, you can put your concerns in an email, outlining the issues, your desired outcome, and any other information you believe is relevant and send it to: Kola at Info@globalmigrationltd.com.
You have the right to make a complaint at any time to the UK supervisory authority for data protection issues, the Information Commissioner’s Office (ICO), (https://www.ico.org.uk). We would ask you to provide us with the opportunity to discuss your concerns with you before you contact the ICO:
Changes to this Privacy Notice
If we change this Privacy Notice we will post any updates here for your review. If we change material terms we will provide notice of the revised Privacy Notice for 30 days on our home page at https://globalmigrationltd.com with a link back to this page.
You can print a copy of the full Privacy Notice by pressing Ctrl + P on your keyboard, or navigating to Print Page in your browser.
This Privacy Notice was last updated: 01 December 2020.